PRIVACY NOTICE FOR THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679 – GDPR (GENERAL DATA PROTECTION REGULATION)
Last updated: 27/02/2026
Dear User,
ASSOCIAZIONE FABBRICA INTELLIGENTE LOMBARDIA, with registered office at Via Ercole Oldofredi 23, 20124 Milan, Tax Code and VAT No. 08192390964 (hereinafter the “Controller”), pursuant to EU Regulation No. 2016/679 (hereinafter the “Regulation”), is required to provide you with certain information regarding the use of personal data.
This notice is provided for the website https://smart-growth.afil.it (hereinafter the “Website”), and not for other websites that may be consulted by the user through links. It constitutes an integral part of the Website and of the services we offer. This notice is provided pursuant to Article 13 of the Regulation to those who interact with the web services of the Website.
Your personal data will be processed in accordance with the legislative provisions of the Regulation and the confidentiality obligations therein provided. The processing of your personal data will therefore be carried out in accordance with the principles of fairness, lawfulness, transparency, purpose limitation and storage limitation, data minimization and accuracy, integrity and confidentiality, as well as the accountability principle pursuant to Article 5 of the Regulation.
DATA CONTROLLER AND DATA PROCESSORS
The Data Controller is ASSOCIAZIONE FABBRICA INTELLIGENTE LOMBARDIA, as identified above. The updated list of Data Processors may be requested at the following email address: direzione@afil.it.
TYPE OF DATA PROCESSED
Browsing data
The computer systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. These are pieces of information that are not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment. At present, web contact data are not retained for more than seven days.
Data voluntarily provided by the user
Contacts section:
the optional, explicit and voluntary sending of personal data requested in the contacts section, as well as any other personal data included in the message, will be processed exclusively for purposes strictly related to the request (for example: responding to requests for information sent). Without prejudice to any processing required by law, any other purpose is excluded.
Cookies
Details about the cookies used on the Website are available in the “Cookie Policy”.
PURPOSE AND LEGAL BASIS OF PROCESSING
Personal data collected through the Website are processed by the Controller for the following purposes:
1) Technical operation of the Website and security (browsing logs)
session management, Website security, prevention of abuse and malfunctions;
production of technical logs and event records.
Legal basis:
Legitimate interest of the Controller (Art. 6(1)(f) GDPR) to ensure the proper functioning, security, and availability of the Website.
2) Management of requests through the “Contacts” form
responding to requests received through the Website forms or via email.
Legal basis: Execution of pre-contractual measures adopted at the request of the data subject (Art. 6(1)(b) GDPR).
3) Management of cookies and similar tools
The use of technical, analytical, and profiling cookies is governed by the “cookie policy” and by the consent management platform (CMP).
Legal bases:
Technical cookies → technical necessity (no consent required)
Anonymized analytical cookies → legitimate interest (Art. 6(1)(f))
Non-anonymized analytical / marketing cookies → consent (Art. 6(1)(a)) through the cookie banner.
NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL
The provision of personal data through the Website, although not always mandatory, may be necessary in order to allow the provision of the services requested through the Website or to comply with legal or statutory obligations.
In particular:
for the purpose referred to in point 1 (technical operation and security of the Website)
the provision of browsing data only is necessary to allow consultation of the Website; failure to provide such data (e.g., blocking network logs) may compromise browsing or security.
for the purpose referred to in point 2 (requests via “Contacts”)
the provision of data is necessary in order to properly respond to the request; failure to provide such data will make it impossible to obtain a response.
for the purpose referred to in point 3 (cookies and similar tools)
technical cookies are necessary for the proper functioning of the Website; other cookies may be refused through the banner and the CMP without affecting browsing, except for personalization or non-essential functionalities.
PROCESSING METHODS AND DISCLOSURE TO THIRD PARTIES
Personal data collected through the Website are processed using electronic tools and, where necessary, also paper-based means, in compliance with the principles of lawfulness, fairness, transparency, minimization, and storage limitation. Processing is carried out exclusively for the time necessary to achieve the purposes indicated in this Privacy Policy.
The Controller applies appropriate technical and organizational measures pursuant to Article 32 GDPR to prevent loss, destruction, unauthorized access, or unlawful use of data, ensuring the confidentiality and integrity of the processed information. Data may only be processed by personnel expressly authorized by the Controller and by third parties providing services functional to the operation of the Website or the related procedures (e.g., hosting providers, cloud systems, IT maintenance, communication service providers), appointed where required as Data Processors pursuant to Article 28 GDPR.
Pursuant to Article 6, paragraphs 1(b) and (c) of the GDPR, without the need for explicit consent, personal data may be communicated to judicial authorities or public bodies for legal obligations or in response to requests from such authorities. In cases where recipients independently determine the purposes and means of processing (e.g., public authorities), such subjects will act as independent Data Controllers. Personal data will not be disclosed without the prior consent of the data subject.
Within the processing activities carried out through the Website, there are no automated decision-making processes, including profiling, pursuant to Article 22 GDPR.
TRANSFER OF PERSONAL DATA
Personal data processed through the Website are stored within the European Economic Area (EEA). If, for technical or operational needs related to the services used (e.g., hosting providers, newsletter providers), it becomes necessary to transfer data to third countries, the Controller will ensure that such transfer takes place in compliance with Articles 44–49 GDPR, adopting one of the provided conditions of lawfulness (adequacy decisions, standard contractual clauses, and supplementary measures).
RIGHTS OF THE DATA SUBJECT
The data subject may exercise at any time the rights provided for in Articles 15–22 GDPR, including:
- access to personal data;
- rectification or completion;
- erasure (“right to be forgotten”);
- restriction of processing;
- objection for legitimate reasons;
- data portability;
- withdrawal of consent, where processing is based on it;
- complaint to the Supervisory Authority.
To exercise your rights you may send a registered letter with return receipt to AFIL – ASSOCIAZIONE FABBRICA INTELLIGENTE LOMBARDIA, c/o Innovhub, Via G. Colombo 83, 20133 Milan (MI), or an email to direzione@afil.it.
CHANGES TO THE PRIVACY POLICY
The Controller reserves the right to update this Privacy Policy at any time. Changes will be published on the Website; therefore, we invite you to regularly consult this section.